View the motion [here](https://drive.google.com/file/d/1QdpQBhnFA3ssiucuLVfI-h-OcFi2IrFP/view?usp=sharing).

@singhski @actxrz

@singhski @actxrz

For those reasons alone, any reliance on New York v. Burger and the regulatory statute, 6 M.S.C. 4 § 2202, is actually fundamentally misplaced. The first seizure—namely, the smashing of Plaintiff’s windows and physical interference with the vehicle—was not carried out pursuant to any regulatory authority, but rather stemmed from a dispute over alleged illegal parking. Compl. ¶¶ 8–10. The second seizure, which involved the warrantless search of the vehicle’s cargo compartments, occurred only after the officer presumed that the vehicle’s parking violation gave him cause to search. But that assertion conflates parking enforcement with regulatory inspection authority and ignores the basic requirement that such searches must be supported by “reasonable cause” and conducted in a reasonable manner. See supra Section I.A. No provision of 6 M.S.C. 4 § 2202 authorizes warrantless entry or destruction of property based solely on a parking violation.